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statute of limitations.17 None of the cited sections are
inconsistent with our interpretation that section 6229 provides
an alternative minimum period of limitations. Section 6229(a)
holds open the section 6501 limitations period as to all partners
for a fixed period of time, thereby providing a minimum period
within which to assess adjustments attributable to partnership
items against all partners. A general reference to section
6229(a) as a period of limitations does not demonstrate any
intention as to whether the minimum period provided in section
6229(a) exclusively defines the period of limitations, versus
only a minimum period, or whether it operates on all assessments
versus only specified assessments. Those questions must be
answered by examining the provision referenced, which, in the
instance of section 6229(a), refers to a period for assessing any
tax which “shall not expire before” the later of the partnership
return filing or due date. The “period for assessing any tax”
that is specifically referred to in section 6229(a) must, of
17Petitioner cites: (1) Sec. 6503(a)(1) ("the period of
limitations provided in section 6501 or 6502 (or section 6229
* * *)"); (2) sec. 6229(h) ("the running of the period of
limitations provided in this section"); (3) sec. 6230(d)(1) ("the
period of limitation prescribed in section 6229 with respect to
such partner for assessment of any tax attributable to such
[partnership or affected] item."); (4) sec. 6228(a)(3)(C) ("the
expiration of the period prescribed by section 6229 for making
assessments of tax attributable to partnership items for such
taxable year."); and (5) sec. 6234(g)(2) ("the period prescribed
by section 6229 for assessing any tax under subtitle A which is
attributable to any partnership item or affected item for the
taxable year involved.").
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